Securities Compliance Group, Inc.
800 W. Fifth Ave, Suite 201a
Naperville, IL 60563
(888) 978-9901
www.IBankAttorneys.com
July 14, 2014
Via Overnight Courier & Email
Ms. Stacie Gorman
Senior Counsel
Securities and Exchange Commission
Division of Corporate Finance
Washington, D.C. 20549
Re:
Realco International, Inc.
Registration Statement on Form S-1
Filed March 26, 2014
File No. 333-194811
Dear Ms. Gorman,
To follow you will find the response of Realco International, Inc. to the Securities and Exchange Commission's (the “Commission”) correspondence dated July 3, 2014.
Comment letter dated July 3, 2014
General
1.
We note your response to comment 2 and it appears that you have deleted your accounting policy disclosure related to organization costs within the notes to your financial statements. Please disclose your accounting policy for both organization and offering costs and disclose the total amount of organization and offering costs incurred as of the most recent balance sheet date all within the notes to your financial statements.
Response
The disclosure in question was added to Note 2. Of the financial statements, Summary of Significant Accounting Policies
Financial Statements
Contents, pages 34 and 35
2. Please update the dates in your table of contents such that they are consistent with the actual periods included within your financial statements.
Response
The table of contents was updated to reflect the period ending March 31, 2014
Exhibit 23.1
3. Please include an updated consent from your auditors in an amended filing on Form S-1. The updated consent should include the appropriate date of the auditors’ report and the appropriate financial statement periods
Response
Please note the updated Exhibti 23.2 reflecting the appropriate financial statement periods.
Conclusion
Kindly contact this office should the Commission require further disclosure. Thank you for your time and consideration.
Yours very truly,
/s/ Adam S. Tracy
Adam S. Tracy
Attorney for Realco International, Inc.